People v. Stevens CA2/5, B268146

Defendant James Charles Stevens committed offenses on March 31, 2015, after Proposition 47 took effect.
Amended felony complaint charged theft with unlawful use of access cards (Pen. Code, § 484e(d)) for counts 2–4 and forgery for count 5; it also alleged a prior serious felony conviction (aggravated assault, § 245(a)(1)) and nine prior prison terms.
On May 14, 2015, Stevens accepted a negotiated plea/sentence bargain: pleaded guilty to all counts and admitted the priors in exchange for a stipulated 5-year state prison term; he was advised of potential penalties if tried.
On September 9, 2015, Stevens filed a Penal Code § 1170.18(a) petition seeking resentencing under Proposition 47 as to the three § 484e(d) convictions.
The trial court (Judge Laesecke) denied the petition, concluding the convictions were ineligible under § 1170.18 and noting the prior serious felony allegation; the Court of Appeal affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stevens was eligible for resentencing under Penal Code § 1170.18	People: § 1170.18(i) bars resentencing for persons with prior serious-felony convictions; Stevens admitted such a prior	Stevens: sought recall/resentencing of § 484e(d) convictions under Prop 47	Held: Ineligible — prior serious felony admission precludes § 1170.18 relief
Whether Stevens is estopped from challenging his sentence because of the plea bargain	People: Stevens knowingly agreed to a 5‑year bargain and admitted priors; he cannot now attack that agreed sentence	Stevens: sought resentencing despite the plea bargain	Held: Estoppel — plea agreement bars collateral attack on agreed sentence
Whether § 1170.18 applies when the offense occurred after Prop 47 enactment	People: Prop 47 already in effect at time of offense; § 1170.18(a) only applies where the act would have reduced the offense to a misdemeanor if not in effect	Stevens: argued for relief under § 1170.18(a)	Held: No § 1170.18(a) relief — petition properly denied because eligibility requirements not met
Whether trial court erred in denying petition procedurally	People: denial proper on substantive ineligibility and plea-estoppel grounds	Stevens: procedural challenge to denial (implied)	Held: No error — denial affirmed on legal grounds

In re Lucas, 53 Cal.4th 839 (discussing statutory interpretation principles)
People v. Lawrence, 24 Cal.4th 219 (statutory construction and eligibility rules)
People v. Nuckles, 56 Cal.4th 601 (postrelease supervision advisory consequences)
People v. Hester, 22 Cal.4th 290 (plea bargain estoppel on collateral attack)
People v. Banuelos, 130 Cal.App.4th 601 (ineligibility for Proposition 47 relief due to prior convictions)